air quality policy division d p a q pm 2.5 final nsr implementation rule nat’l tribal air assoc....

Air Quality Policy DivisionDP

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PM2.5 Final NSR Implementation Rule

Nat’l Tribal Air Assoc.July 16, 2008

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Final Rules

• Signed by Administrator on Thursday, May 8, 2008

• Posted www.epa.gov/nsr

• FR publication: May 16, 2008

• Effective date: July 15, 2008

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Summary of Requirements• General Provisions

– PM2.5 precursors– Major source threshold– Significant emissions rates: PM2.5 & precursors– Condensable PM

• PSD Requirements– BACT for PM2.5

– PM2.5 Increments, SILs, SMC– Air Quality Analysis: Modeling & Monitoring

• Nonattainment NSR Requirements– Offsets: PM2.5 & Precursors– Offset Ratios– Interpollutant Trading

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General Provisions• PM2.5 Precursors

– SO2 is always a precursor

– NOx: “presumed in” precursor -Demonstration may be made that NOx emissions in a specific area do not

contribute significantly to ambient PM2.5 concentrations

– VOC/ammonia: “presumed out” precursors -Demonstration may be made that VOC and/or ammonia emissions in a

specific area contribute significantly to ambient PM2.5 concentrations

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General Provisions

• Major Source Threshold– PSD:

• 100 tpy for source categories listed in 40 CFR 51.166(b)(1)(i)(a) and 52.21(b)(1)(i)(a)

• 250 tpy for all other source categories

– NA NSR• 100 tpy for all source categories

• Significant Emissions Rate– 10 tpy, PM2.5 emissions– Precursors SO2, NOx, VOC = 40 tpy

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General Provisions

• Condensable PM (CPM)– NPRM stated that CPM must be accounted for in

permits for PM10/PM2.5

– Based on comments received for NPRM, EPA adopted transition period (TP) to validate CPM test methods

– EPA recommends that states not require permits to account for CPM for PM10/PM2.5 during TP (states not precluded from addressing CPM in permits if SIP requirements exist)

– TP ends on a date established in test method rulemaking or 1/1/2011, whichever is earlier

– After TP ends, NSR permits for PM10/PM2.5 must account for CPM emissions

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PSD Program for PM2.5

• Key Dates– Effective date of PM2.5 rules

• 40 CFR 52.21 (EPA & delegated states) - 60 days from date of Federal Register publication

• 40 CFR 51.166 (SIP-approved state programs) – 60 days from date of FR publication;

– Implementation date of PM2.5 program:• EPA & delegated states: Effective date of 40 CFR 52.21 • SIP-approved programs: States have up to 3 years to revise

SIP consistent with 40 CFR 51.166; until then states may follow PM10 surrogate policy

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• BACT– Applies to emissions units at new major

sources where source emits significant amounts of direct PM2.5

– Applies to emissions units that are part of major modification for direct PM2.5

– Applies similarly to precursors—SO2 and NOx

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• Air Quality Analysis– Applicants must demonstrate compliance with PM2.5 NAAQS

• Permits issued under Federal PSD program (40 CFR 52.21) must use PM2.5 on effective date of new rules

• Permits issued under state PSD program (40 CFR 51.166) may continue using PM10 surrogate policy until SIPs are revised (States have up to 3 years for SIP revisions)

– Modeling analysis must consider source impacts consistent with PM2.5 monitor site requirements and recommendations

– PM2.5 increments, SILs & SMC to be finalized by 12/08• Preconstruction monitoring

– Applicants must collect ambient monitoring data• Permits issued under Federal PSD program must use PM2.5 data• Permits issued under state PSD program may continue using PM10 surrogate

policy until SIPs are revised (3 years for SIP revisions)– Representative, existing PM2.5 data may be used in lieu of new monitoring

data– EPA is developing a Significant Monitoring Concentration

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• Precursors– Under both Federal PSD program and state

SIP requirements• SO2 always a precursor• NOx is “presumed in”• VOC is “presumed out”

– Demonstration may be made that NOx is not a precursor

– Demonstration may be made that VOC is a precursor

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NA NSR Program for PM2.5

• Key Dates– Effective date of PM2.5 rules

• 40 CFR part 51 app S - 60 days from date of Federal Register publication

• 40 CFR 51.165 (SIP-approved state programs) – 60 days from date of FR publication;

– Implementation date of PM2.5 program:

• All states: begin PM2.5 program on effective date of

appendix S; PM10 surrogate program no longer applies

• SIP-approved NA NSR rules: States have up to 3 years to revise SIP consistent with 40 CFR 51.165; until then states must follow appendix S requirements for PM2.5

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• LAER, Offsets and other requirements apply to PM2.5 on effective date of appendix S

• PM10 surrogate policy for NA no longer applies

• As fallback, EPA will implement PM2.5 requirements via app S

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• Interpollutant Trading (Offsets)– Direct PM2.5 emissions may be offset with

reductions of • direct PM2.5 emissions (at least 1:1 ratio)

• other precursors, e.g., – SO2:PM2.5 @ 40:1

– NOx:PM2.5 @ 200:1 (east)

– NOx:PM2.5 @ 100:1 (west)

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• Precursors– Under appendix S (for interim implementation)

• only SO2 is a precursor

– Under requirements for SIPs• SO2 is always a precursor• NOx is “presumed in”• VOC/ammonia are “presumed out”• Precursor presumptions may be rubutted by

making appropriate demonstration

air quality policy division d p a q pm 2.5 final nsr implementation rule nat’l tribal air assoc....

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